UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF PENNSYLVANIA

Kristin C. Perez Haines :

1869 Ironbridge Road : JURY TRIAL DEMANDED

Columbia, PA 17512 :

:

v. :

: CIVIL ACTION 

Rodney Gene Lee :

18101 Bunkerhill Road :

Parkton, MD 21120 : No.

:

PLAINTIFFS' COMPLAINT

PARTIES

1. Plaintiff, Kristin C. Perez Haines, is an adult natural person residing at the

captioned address.

2. Defendant, Rodney Gene Lee, is an adult natural person residing at the captioned

address.

JURISDICTION and VENUE

3. Jurisdiction is conferred upon this Court pursuant to 28 U.S.C.A. §1332 since the

parties are diverse and the amount in controversy exceeds the sum of Seventy-Five Thousand

Dollars ($75,000.00), exclusive of interest and costs.

 4. Venue is appropriate in this jurisdiction as the underlining incident occurred in this

venue.

Case 2:02-cv-04432-BWK Document 1 Filed 07/03/2002 Page 1 of 5
KRISTIN C. PEREZ HAINES V. RODNEY GENE LEE

 5. On or about August 3, 2000, the Plaintiff, Kristin C. Perez Haines, (hereafter

“Plaintiff”) was operating a 1997 Pontiac GrandAm, Pennsylvania licenses plate number CDD

7072 (hereafter “Haines vehicle”) Northbound on South Angle Street at or near its intersection

with West Main Street in the Borough of Mount Joy, Lancaster County, Commonwealth of

Pennsylvania.

6. At the same time and place Defendant, Rodney Gene Lee, was operating a 1990

International Tractor Trailer, Maryland license plate number 232F81 (hereafter the “Lee vehicle”).

7. The Lee vehicle was facing north bound on South Angle Street and was infront of 

the vehicle operated by Plaintiff.

8. Defendant Rodney Gene Lee, hereafter (“Defendant”) while reversing the Lee 

vehicle, struck the Haines’s vehicle.

9. As a result of the impact Plaintiff sustained injuries and damages as set forth at

length herein.

10. The aforesaid incident and the injuries sustained by Plaintiff were caused by the 

negligence and carelessness of Defendant Lee which included:

(a) failing to have the Lee vehicle under proper and adequate control;

(b) failing to keep a proper lookout for the Plaintiff's vehicle;

(c) failing to properly operate the Lee vehicle;

(d) operating the Lee vehicle at an excessive rate of speed under the

circumstances;

(e) failing to respect the rights, position and safety of the Perez Haines vehicle;

Case 2:02-cv-04432-BWK Document 1 Filed 07/03/2002 Page 2 of 5
(f) failing to abide by the "assured clear distance rule";

(g) failing to properly reverse the Lee vehicle;

(h) failing to abide by the Rules of the Road as set forth in 75 Pa.C.S.A.

Chapter 33. 

(i) any and all acts of negligence which may be discovered.

11. This incident resulted solely from the negligence and recklessness of the 

Defendant, and was in no manner whatsoever due to any act or failure to act on the part of

Plaintiff.

12. As a result of this incident, Plaintiff Kristin Perez Haines suffered injuries including 

Chronic cervical and lumbar injuries and disc injuries at the L3-4 and L4-5, and C5-6 level, all or

some of which have caused her and continue to cause her great pain and agony and have

prevented her and likely in the future will prevent her from attending to her daily occupational and

social activities, all to her great financial damage and loss.

13. By reason of the aforesaid incident, Plaintiff Kristin Perez Haines was caused to

suffer great harm and potentially permanent injuries to her body.

14. Further, Plaintiff Kristin Perez Haines has been compelled to spend various sums

of money for medicine and medical attention in and about endeavoring to treat and cure herself of

her injuries, and will be compelled to spend additional sums in the future.

15. As a further result of this accident, Plaintiff Kristin Perez Haines has or may suffer

a severe loss of earnings and impairment of earning capacity and powers; said loss of income

and/or impairment of earning capacity.

16. As a further result of this accident, Plaintiff Kristin Perez Haines has suffered

Case 2:02-cv-04432-BWK Document 1 Filed 07/03/2002 Page 3 of 5
severe physical pain and mental anguish and humiliation and may continue to suffer same for an

indefinite period of time in the future.

WHEREFORE, Plaintiff, Kristin Perez Haines, demands damages from Defendant

Rodney Gene Lee, individually and jointly and severally, in an amount in excess of Seventy-Five

Thousand ($75,000.00) Dollars, plus interest, delay damages, costs of suit, and such other remedy

as seen fit by this court.

LAW OFFICES OF GREGG DURLOFSKY

BY: 

GREGG R. DURLOFSKY, ESQUIRE

111 West Germantown Pike

Plymouth Meeting, PA 19462

(610) 834-9483

Attorney for Plaintiff

Case 2:02-cv-04432-BWK Document 1 Filed 07/03/2002 Page 4 of 5
UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF PENNSYLVANIA

Kristin C. Perez Haines :

1869 Ironbridge Road :

Columbia, PA 17512 :

:

v. :

: SUMMONS 

Rodney Gene Lee :

18101 Bunkerhill Road :

Parkton, MD 21120 :

To: Rodney Gene Lee

You are hereby summoned and required to serve upon Gregg R. Durlofsky, Esq,

Plaintiff’s attorney, whose address is 111 West Germantown Pike, Plymouth Meeting, PA 19462,

an answer to the complaint which is herewith served on you, within 20 days after service of this

summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will

be taken against you for the relief demanded in the complaint.

_____________________________

Clerk of Court

Sealed

Dated:

Case 2:02-cv-04432-BWK Document 1 Filed 07/03/2002 Page 5 of 5